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Ralph Russo Comment On Regulatory Notice 21-19

Ralph Russo
Investor

Thankfully, we have enough historic data to narrow the amount of possible solutions to the short interest reporting problem. In my view, there are only 2 solutions that will restore integrity in the markets and ensure future stability; 1) Make the ENTIRE system transparent (yes, every trade!) and provide free real-time data to everyone...Result: All market participants can help police the market by either shining light on fraud or taking a counter position. 2) Allow short positions to be hidden BUT we'd need to go back to paper certificates where it would be IMPOSSIBLE to create naked shares. Plus, we would need near-instant settlement, real penalties for illegal actions (jail?!?), and retail investors MUST know that their shares are in their hands (example. not lent out by broker without their permission) Any solution that doesn't include either of the above is inadequate.